Multistate Income Allocation and Apportionment (Completed)

Date: Thursday, December 1, 2022
Instructor: Open Weaver Banks, Hodgson Russ LLP
Begin Time:  9:00am Pacific Time
10:00am Mountain Time
11:00am Central Time
12:00pm Eastern Time
CPE Credit:  2 hours for CPAs

According to the U.S. Supreme Court, apportioning income among the states resembles “slicing a shadow.” That is because states employ a patchwork of sourcing rules and formulas to determine how much of a business’s income is subject to tax. Within the same state different rules may apply to different types of entities (for example businesses operating as partnerships, C corporations or S corporations). And different rules apply to different types of receipts, such as receipts from the sales of services versus receipts from sales of tangible personal property. This webinar, taught by Open Weaver Banks from Hodgson Russ LLP, will review different state approaches to apportioning income and recent developments in this constantly evolving area of tax law, including legislative developments and court decisions.

Who Should Attend
All CPAs, enrolled agents, tax return preparers, tax attorneys, corporate attorneys, and other practitioners who review or are responsible for preparing multistate tax returns for clients or advise on multistate tax issues will benefit from this insightful webinar.

Topics Covered

  • Review of the historical role of UDITPA (Uniform Division of Income for Property Tax Purposes)
  • Understanding the difference between business income and nonbusiness Income
  • Overview of how nonbusiness income is allocated
  • Discussion of different methods for apportioning business income
  • Examination of the impact of single sales factor sourcing
  • Review of the impact of choice of entity on apportionment
  • Identification of combined reporting apportionment issues
  • Discussion of "alternative apportionment" options
  • Overview of apportionment audits and appeals

Learning Objectives

  • Identify the basic rules of apportionment employed by states
  • Recognize the unique rules that apply to different entities and types of income
  • Gain awareness of apportionment issues that may arise in audits and appeals


Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites

Advance Preparation

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